Effective as of 31 January 2023, Ukraine introduced a new set of personal sanctions against 182 Russian and Belarusian legal entities, mainly transport and leasing companies as well as chemical enterprises, and 3 individuals — citizens of the Russian Federation.[1] The sanctions package, according to the President of Ukraine Volodymyr Zelenskyy, is aimed at companies involved in transporting Russian military equipment and soldiers.
The Decision imposes extensive sanctions, including asset freeze; ban on trade operations; ban on transit of resources, flights and transportation within the territory of Ukraine; suspension of the performance of economic and financial obligations; restriction on the exit of capital from Ukraine; prohibition on participating in privatization and lease of state property, as well as public and defense procurement; ban on securities transactions; termination of trade agreements and joint projects; and prohibition on concluding contracts and executing transactions. Among others, the sanctions affect the following categories of persons:
- Russian and Belarusian transport companies: Inter Cargo Company JSC, Gazpromtrans LLC, Russian Container Company JSC, First Industrial Operator LLC, Investment Car Company LLC, Cargo Company JSC, Federal Cargo Company JSC, Belorussian Railways State Association, EvroTransVagon LLC, etc.
- Russian and Belarusian chemical enterprises: Uralkaliy PJSC, Moscow Coke and Gas Plant JSC, Titan Group of companies JSC, Shchekinoazot JSC, Bashkir Soda Company JSC, Gomel Chemical Plant Open JSC, Belaruskaliy Open JSC, Lakokraska Open JSC, Omsk Carbon Mogilev Foreign LLC, etc.
- Russian and Belarusian leasing companies: PSB Leasing LLC, Gazprombank Leasing LLC, UniCredit Leasing LLC, Rietumа Leasing LLC, etc.
- Russian coal energy enterprise: Siberian Coal Energy Company JSC
- Russian citizens — individual entrepreneurs: Matveev Valerii Borisovich, Belosokhov Sergei Alekseevich and Strok Vladimir Nikolaevich
The full lists of legal entities and individuals subject to sanctions are set forth in the annexes to the Decision. Any party dealing with persons on the sanctions lists must carefully assess the exact scope of the sanctions imposed and the implications of dealing with such entities and individuals.
[1] Presidential Decree No. 50/2023 dated 28 January 2023 “On the Decision of the National Security and Defense Council dated 28 January 2023 “On Imposing and Amending of Personal Special Economic and other Restrictive Measures (Sanctions)”,” effective from 31 January 2023 (“Decision“).